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Secondary Flight Deck Barrier; safety or politics?



In June 2021 The US government DOT, Headed by Steve Buttigieg, developed the US DOT Spring Regulatory agenda.

Four sections:

  1. Safer and more Equitable Roadways and Vehicles

  2. Safer Workers and Workplace

  3. Climate and Environmental Justice

  4. Economy and Workforce transformation

Full text of the agenda below downloadable

U.S
. Department of Transportation Releases Spring Regulatory Agenda _ US Department of Tra
Download DEPARTMENT OF TRANSPORTATION RELEASES SPRING REGULATORY AGENDA _ US DEPARTMENT OF TRA • 73KB

Part of Section two on the Agenda indicates:


Protect aircraft cockpits with secondary flight-deck barriers (FAA)

Please note that this has not been based on any safety risk mitigation analysis but stipulated in a Regulatory Agenda (downloadable above) and earlier industry lobby.


In practice this would translate in change of Part 121 regulations. Part 121 are operating regulations for operators that provide scheduled services to the public..


In February 2020, the Aviation Rulemaking Advisory Committee (ARAC) produced a recommendation Document to justify the mandate of the installation. Downloadable below.

The document was compiled by a Secondary Barrier Working Group (SBWG) which solicited members of several airline manufacturers (Pilot and cabin attendant )Trade Associations, Airlines and the FAA (no foreign regulators except China's CAAC).


SBWG Recommendation Report (submitted to FAA 3-20-2020)
.pdf
Download PDF • 979KB

A quote from Section 2 of the Recommendation:

On October 5, 2018, Congress enacted P.L 115-254. Section 336 of P.L. 115-254 requires the FAA to issue an order requiring installation of a secondary cockpit barrier on each new aircraft that is manufactured for delivery to a passenger air carrier in the United States operating under the provisions of part 121 of title 14, Code of Federal Regulations.

In 2015 (before the SBWG report) the FAA published Advisory Circular AC 120-110, downloadable below.

The AC refers to an RCTA document DO-329 which is not publicly available.


AC_120-110
.pdf
Download PDF • 51KB

The safety case is to mitigate possible unauthorised access to the flight deck during transitions of crew members to and from the flight deck, i.e. rest room use, meal and drink services and crew changes.


The SBWG recommendation report contains a cost benefit analysis section 4.3, which is basically a cost analysis with the safety benefit not quantified.


The report contains 21 recommendations and section 7 lists these recommendations and also lists consent or dissent from working group members.


Full consensus had recommendation 1, 3 thru 14 and 16-thru 18

Majority of consent with dissent had recommendation 2 and 15

Recommendation without consensus; 19, 20 and 21


Interestingly, Recommendation 13 states the rule should not apply to Part 129 operators.

Part 129 are regulations applicable to foreign operators operating into the United States.


Recommendation 14 stated that the rule should not be applicable to Cargo aircraft.


Recommendation 19 reflects the authoritative hierarchy of the RCTA superseding that of the FAA. RTCA is an industrial lobby association with representatives from the industry only

RTCA's annual report 2020 is downloadable below:

RTCA_Annual-Report-2020_Final
.pdf
Download PDF • 3.07MB

Recommendation 20; minimum of two flight attendants on every flight


Recommendation 21; Implementation Timeline for the new rule (36 Months versus 18 Months after final rule issue)


After all the preliminary publications it was placed on the, essentially, political DOT agenda which culminated so far into the Notice of Proposed Rulemaking (NPRM) open for public consultation. This public consultation will most certainly not be able to stop the regulation, considering the fact that this was so heavily lobbied and prepared.


The NPRM lists consideration of implementation of the rule into Part 25 (large transport aircraft certification regulations), which would broaden the requirement from Part 121 (scheduled service operators) to everything, including foreign operators (Part 129) and corporate and Part 135 (on demand) operators, which would considerably increase the financial burden on the industry over just Part 121 operators.

It also proposes an implementation period of 24 months.

Bear in mind that this would include development and certification of the following:

  • Design of the barrier

  • Testing and certification of the design, including failure mode and effect analysis (crew trapped between two barriers, workload effects, urgent flight deck access in (medical) emergencies, etc.)

  • Developments of Instructions for Continued Airworthiness (ICA) manuals.

  • Development of operating instructions

  • Development of training instruction and training crews

  • Production of installation drawings and kits

  • Installation of the modification on all aircraft

The response from existing operators will probably be many but how much clout they will have is questionable



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